ARTICLE IN PRESS Journal of Environmental Economics and Management 48 (2004) 632–654 Incentives for environmental self-regulation and implications for environmental performance Wilma Rose Q. Anton,a George Deltas,b and Madhu Khannac, a Department of Economics, University of Central Florida, 302-J Business Administration II, P.O. Box 161400, Orlando, FL 32816-1400, USA b Department of Economics, University of Illinois at Urbana-Champaign, 450 Wohlers Hall, 1206 South Sixth Street, Champaign, IL 61820, USA c Department of Agricultural and Consumer Economics, University of Illinois at Urbana-Champaign, 440 Mumford Hall, 1301 W. Gregory Dr., Urbana, IL 61801, USA Received 7 October 2002; revised 9 May 2003; accepted in revised form 30 June 2003 Abstract The increasing reliance of environmental policy on market-based incentives has led firms to shift from regulation-driven management approaches to proactive strategies involving the voluntary adoption of environmental management systems (EMSs). Count data and quantile regression analyses reveal that liability threats and pressures from consumers, investors and the public are motivating EMS adoption and that consumer pressures are particularly effective in increasing the comprehensiveness of EMSs of firms that would otherwise be adopting a limited EMS. We also find that a more comprehensive EMS leads to lower toxic emissions per unit output particularly for firms with higher pollution intensity in the past. EMSs result in reductions in both off-site transfers and on-site releases per unit output. Finally, we find that regulatory and market-based pressures do not have a direct impact on toxic releases but an indirect effect by encouraging institutional changes in the management of environmental concerns. r 2003 Elsevier Inc. All rights reserved. Keywords: Environmental management systems; Environmental management practices; Environmental self-regulation; Toxic releases; Voluntary adoption; Regulatory pressures; Market-based pressures 1. Introduction There is a growing trend among corporations towards environmental self-regulation. ‘‘Business-led’’ initiatives such as development of firm-structured environmental management Corresponding author. Fax: +1-217-333-5502. E-mail address: [email protected] (M. Khanna). 0095-0696/$ - see front matter r 2003 Elsevier Inc. All rights reserved. doi:10.1016/j.jeem.2003.06.003 ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 633 systems (EMSs), participation in trade association programs emphasizing codes of environmental management (e.g. Responsible Care program of the American Chemical Council), and adoption of international certification standards for environmental management, such as the International Standards Organization are becoming widespread. These initiatives represent an internally motivated institutional change in corporate culture and management practices towards environmental self-regulation by incorporating environmental concerns in production decisions. These efforts at environmental management by firms and the potential that they hold for identifying cost-effective and self-enforcing strategies for pollution control have caught the attention of regulatory agencies and led to a spate of programs in the US to encourage greater adoption of EMSs [26,28,29].1 These policy initiatives are based on the presumption that EMSs improve environmental performance; a presumption that is yet to be validated. While there is some evidence that toxic releases emitted by firms have decreased by 43% over the 1988–97 period (even though they are not directly regulated), the role of EMSs in achieving this reduction has not been systematically examined2 [8,30]. Since most EMSs focus only on the means (proactive efforts) for pollution control rather than the ends (actual performance improvement), they do not necessarily guarantee an improvement. This paper has two purposes. First, it examines the factors that influence the adoption of EMSs by firms. These EMSs consist of several environmental management practices (EMPs), such as, having an environmental policy, training and rewarding workers to find opportunities to prevent pollution, setting corporation-wide internal standards that are maintained even by facilities in other countries with lower environmental standards, undertaking internal environmental audits and adopting the philosophy of total quality management (TQM) in environmental management. Firms have considerable flexibility in the extent to which they adopt EMPs and thus the comprehensiveness of the EMS has been observed to vary a great deal across firms [15]. We examine the factors that explain differences in the choice of the comprehensiveness of the EMS adopted by a sample of S&P 500 firms. The second purpose of this paper is to establish the extent (if any) to which the comprehensiveness of the EMS has an impact on toxic release intensity of the sample firms. In measuring this impact of EMS adoption on environmental performance, we consider the possibility that the factors that influence the extent of EMS adoption also have a direct impact on reducing emissions. Our research adds to the growing literature on voluntary measures taken by firms to improve their environmental performance (see survey in [16]). Within the empirical literature on environmental self-regulation there are many studies examining the motivations for firms to participate in voluntary programs established by the regulatory agency, such as the 33/50 program 1 These programs are offering technical assistance, recognition, financial and regulatory benefits to firms that implement an EMS [9]. The interest in investigating the potential of EMSs as a policy tool can be inferred from the broad participation in the 1999 National Research Summit on EMSs organized by a multi-state working group [23] of eleven state environmental agency officials, the USEPA and institutions such as the Brookings Institution, the National Academy of Public Administration and the Council of State Governments. Further information can be found at http:// www.mswg.org. 2 There is some anecdotal evidence at the firm level that self-initiated environmental management strategies are leading to improvements in environmental performance. As part of the Voluntary Initiative for Source Reduction spearheaded by the EPA Office of Pollution Prevention and Toxics, a Dow Chemical facility reported a reduction in emissions of 7 million pounds as well as savings of over $5 million over a period of 2 years [30]. ARTICLE IN PRESS 634 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 [4,5,31,17], Green Lights [11,31] and WasteWise [31]. Some studies have also examined the motivations for voluntary actions initiated by firms or trade associations unilaterally, such as adopting an environmental plan [13] or an EMS [15], participating in the Responsible Care program of the chemical industry [20] or adopting ISO 14001 management practices [10]. With the exception of Khanna and Anton [15] and Dasgupta et al. [10], other studies have focused on explaining the decision to participate or not to participate in a voluntary activity. This study, like the above two papers, explains the observed variability in the comprehensiveness of the EMS, but differs in that it also examines the impact of various incentives on the distribution of the count of EMPs adopted using quantile regression methods. The second contribution of our study is to the growing body of work examining the implications of voluntary initiatives for environmental performance. This literature has found mixed results. Khanna and Damon [17] find that participation in the 33/50 program led to a statistically significant decline in releases of 33/50 chemicals while Dasgupta et al. [10] find that adoption of ISO 14001 led to a significant improvement in the compliance status of Mexican firms. However, King and Lenox [20] find that the rate at which members of Responsible Care were improving their absolute and relative performance was insignificantly different from that of non-members. This paper shows that consumer and (possibly) investor pressure, along with potential future liability and the scale of past emissions, are the most relevant determinants of the extent of EMS adoption. Interestingly, our quantile regression analysis shows that the effect of consumer pressure is stronger on the firms that would have otherwise adopted the fewest of EMPs. Using data from the Toxics Release Inventory (TRI), we find that the extent of EMS adoption has a significant negative impact on the intensity of toxic emissions particularly among firms with past release intensity that exceeded that of the median firm. We found no evidence that the consumer, investor, and future litigation risk factors that influence the comprehensiveness of EMSs have any direct effect on toxic release intensity. Therefore, our study establishes that these factors reduce emissions intensity indirectly only, through encouraging institutional change in the operation of the firms. This paper is divided into six sections. Section 2 discusses the conceptual framework that underlies the empirical methodology developed in Section 3. Section 4 presents a discussion of the data and variables used. Finally, results and conclusions are in Sections 5 and 6. 2. Conceptual framework 2.1. Preliminaries EMSs represent an organizational change within corporations and an effort for self-regulation by defining a set of formal environmental policies, goals, strategies and administrative procedures for improving environmental performance [24]. Very often they involve applying the concept of TQM to identifying opportunities for making continuous improvements in product quality and in reducing pollution or manufacturing waste. As a result, EMSs have the potential to enhance the effectiveness with which inputs are used in the production process and, since any input not converted to output is by definition an effluent, to thereby reduce waste generation at source ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 635 [19,25]. We assume that a rational firm chooses both the comprehensiveness of its EMS and its level of pollution to maximize its net benefits. The costs and benefits of pollution and EMSs can be expected to vary across firms and it would, therefore, be rational for firms to differ in the level of pollution they generate and in the comprehensiveness of the EMS they adopt. Our conceptual framework consists of (i) an emissions equation, which relates the ith firm’s pollution intensity at a point in time, Yi ; to a vector of observed exogenous firm-specific variables, Xi (that proxy for the costs and benefits of pollution generation), the comprehensiveness of its EMS, Ei ; and unobserved factors e1i ; and (ii) an adoption equation, which relates the comprehensiveness of the firm’s EMS, Ei ; to a vector W i (that captures the factors that influence the benefits and costs of choosing an EMS) and unobserved factors, e2i : Some of the variables included in W i are likely to be also included in X i : Similarly, the unobserved variables (i.e., disturbance terms) of the adoption and emissions intensity equations, e1i and e2i ; are also likely to be correlated. For example, one such unobserved variable could be the ‘green’ preferences of the current management which would affect both the choice of the EMS and the current level of pollution intensity even after conditioning for observed variables. In order to avoid endogeneity bias, we estimate the emissions equation using instrumental variables (IV). Since the adoption decision is assumed not to depend on current emissions, but rather to depend on the level of past emissions, no such endogeneity problem arises in its estimation. Details on the specification and estimation of the adoption and emissions equations are discussed in Section 3. In the remainder of this section, we discuss the dependent variables and the variables that form the vectors X i and W i : 2.2. Determinants of the comprehensiveness of an environmental management system The dependent variable, Ei ; measures the comprehensiveness of the firm’s EMS and is defined as the sum of the EMPs adopted by that firm. We now discuss the observable factors that are expected to influence the choice of the EMS, and which should be included in W i : The existing literature suggests that firms may undertake voluntary environmental initiatives to reduce the costs of compliance with existing regulations, reduce the threat of regulation and shape future regulations, improve reputation and relations with stakeholders that include consumers, investors and communities, and in response to competitive pressure from other firms in the industry (see [16]). We proxy the impact of existing mandatory environmental regulations using two explanatory variables: inspections received by firms to enforce compliance and the number of Superfund sites for which a firm has been listed as potentially responsible. Firms are subject to periodic inspections to enforce compliance with mandatory regulations such as the Clean Air Act and the Clean Water Act. The variable INSPECTIONS represents the number of regulatory inspections made on a firm. A firm that has been subjected to a higher number of inspections might face a greater chance of receiving penalties in the future if it does not signal its ability to reduce its level of waste generation. Firms can be held liable for contamination caused by their hazardous waste streams under the Comprehensive Environmental Response, Compensation and Liability Act. Firms currently listed as potentially responsible parties (PRPs) for a larger number of Superfund sites are more likely to be aware of the liability costs of continuing to generate their past levels of pollution. This variable is called SUPERFUND SITES. ARTICLE IN PRESS 636 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 In addition to regulatory incentives, firms may face pressure from consumers, investors, public/ community, employees and contractors/suppliers to undertake measures to improve their environmental management. Arora and Gangopadhyay [3] demonstrate conditions under which consumer willingness to pay premiums for environmentally friendly products and the desire to relax price competition for vertically differentiated products lead firms to produce ‘‘cleaner’’ products to differentiate themselves from other firms and gain market share. Participation in voluntary programs and adoption of an EMS provides firms with a mechanism to acquire an environmentally friendly reputation and to credibly differentiate themselves from their competitors.3 Although there is not much direct evidence that customers are imposing pressure on firms to adopt EMSs, many firms believe that such demands will arise in the future (see anecdotal evidence in [14]). Firms that produce final goods and are in closer contact with consumers are likely to feel greater pressure or benefit more from improving their environmental friendliness. We use the 4-digit secondary SIC code to classify firms into FINAL GOOD producers represented by a dummy variable equal to 1 if that firm is primarily selling products or services directly to consumers (e.g. pharmaceutical preparations, cosmetics, food products). Firms might adopt EMSs to appear less risky to investors and thus earn preferential rates on insurance and commercial loans [2]. Several studies show that public disclosures of the TRI led to significantly negative stock market returns for poor environmental performers [18]. Such effects are likely to be stronger for firms with a high dependence on the capital market which we proxy by a low SALES–ASSET ratio. This variable is also likely to be an indicator of manufacturing activity. Firms that have a larger volume of toxic releases (TOTAL RELEASES), defined as the sum of on-site toxic releases and off-site transfers,4 are likely to face greater social pressure from communities and stakeholders to undertake measures to improve their environmental performance. Moreover, the adoption of an EMS is likely to impose fixed costs on firms unrelated to the volume of emissions; therefore, we expect that firms with an emissions level greater than a threshold (whose level may differ across firms) would be more likely to have economic benefits from adoption that exceed these fixed costs. Releases in excess of a threshold are likely to have a progressively smaller impact. We also recognize that, as total emissions increase, the benefits to firms of adopting a more comprehensive EMS may increase, although at a diminishing rate. For both of these reasons we use the square root of TOTAL RELEASES as an explanatory variable. We also hypothesize that the adoption decisions of firms are likely to be influenced by the norms set by other firms in the industry. This could be either due to a demonstration effect as firms learn from the experience of other adopters in their industry or due to peer pressure because firms do not want to be singled out as laggards or environmentally unfriendly if other firms in the industry are being more proactive. We, therefore, construct the variable OTHER EMPs by estimating the average number of EMPs adopted by all other firms within the 3-digit SIC code of firm. Additionally, as firms become more visible and face greater scrutiny from their stakeholders, 3 For example, the chemical industry has attempted to develop green markets by instituting the Responsible Care trademark. 4 On-site releases include discharges to air, water, land and those injected underground while off-site transfers are releases sent off-site for treatment, energy recovery or disposal. ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 637 they are likely to have greater incentives to seek ways to improve their environmental reputation. A firm’s exposure to global competitive pressures as well as domestic pressures created by greater visibility is proxied by the number of its domestic facilities (US-FACILITIES) and the number of facilities abroad (NON US-FACILITIES). Adoption of an EMS is also likely to impose costs on firms because it requires greater coordination of activities within the firm and involves employee training, audits, and product and process improvement. Firms that are more innovative are more likely to be able to implement changes in process and product design at a lower cost and achieve input cost savings or higher productivity. The degree of innovativeness of firms is represented by the R&D expenditures per unit sales (RD/SALES). Differences in the costs of implementation may also be determined by the age of assets (AGE) as measured by the ratio between total assets and gross assets [17].5 This variable takes a value between 0 and 1 with higher values indicating newer plant and equipment. Firms with older assets are expected to face lower costs of replacement than firms with newer assets. 2.3. Determinants of environmental performance A firm’s environmental performance may be influenced both by the comprehensiveness of its EMS and by other factors such as output levels, pressure from ‘green’ consumers, potential costs of compliance and liabilities under mandatory environmental regulations, and firm-specific characteristics. The adoption of an EMS could enhance efficiency of input-use and Caswell and Zilberman [7] and Abler and Shortle [1] show that efficiency-enhancing practices reduce the ratio of input-use per unit output and pollution per unit output. However, it is possible that firms may only adopt the outward form of an EMS because it insulates them against stakeholder pressure or to disguise poor performance and avoid regulatory scrutiny [20]. Additionally, in the absence of sanctions for lack of improvement in environmental performance, firms may not follow up EMS adoption with the effort required to really improve environmental performance [24]. Thus, adoption of an EMS does not guarantee improvements in environmental performance and its impact needs to be examined empirically. We measure environmental performance here by the ratio of total emissions to total sales (TOTAL RELEASES/SALES). This measure not only indicates whether adoption did indeed improve the efficiency of production processes and prevent pollution, but it also allows us to scale for differences in firm size. We also examine the impact of adoption on disaggregated emissions using a system of three equations in which the ratios of on-site releases to sales (ONSITE RELEASES/SALES), off-site releases to sales (OFFSITE RELEASES/SALES), and hazardous air pollutants (HAP) to sales (HAP/SALES) are used as dependent variables. Such a disaggregation would allow us to examine if firms target their EMSs towards reducing certain types of pollutants or disposal methods. Additionally, HAP are the pollutants that are the most likely to be regulated in the future. Firms have been aware since 1990 that air emissions of these chemicals will be subject to Maximum Available Control Technology standards that would be based on emissions levels already achieved by the best-performing similar facilities [30]. Reducing these pollutants ahead of time using flexible methods is expected to lower the future costs of 5 Gross assets are defined as total assets plus accumulated depreciation on property, plant and equipment. ARTICLE IN PRESS 638 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 compliance and may also give the firm a strategic advantage relative to its competitors if its performance influences the standards that are set for other firms. Off-site disposal of toxic waste is regulated under RCRA and can occur only in facilities that meet technology-based standards for construction and operation set by the EPA. Firms therefore face a cost for shipping wastes off-site and technical standards for waste treatment and disposal at the end-of-the-pipe [2]. On-site toxic releases are currently not regulated directly but they are likely to generate greater social pressure from communities and other stakeholders since information about them is publicly disclosed. Any variable that influences the comprehensiveness of a firm’s EMS could also, and for the same reasons, influence the firm’s emissions to output ratio conditional on the comprehensiveness of adopted EMS. Therefore, current values of the variables that proxy for regulatory pressures (SUPERFUND SITES), market pressures (FINAL GOOD, SALES–ASSETS ratio), and firmspecific characteristics (AGE, US-FACILITIES, NON US-FACILITIES, R&D/SALES) are included as regressors in the performance equations.6 This allows us to distinguish between the direct and indirect effect (through EMS adoption) of these factors on pollution reduction. We also include the 5 year lagged TOTAL RELEASES/SALES as an explanatory variable to capture persistence in pollution intensiveness that may exist due to the partial fixity of the capital equipment and the underlying technology, that is, as a control for the residual effects from other unobservable variables that cause heterogeneity among firms and affect emissions. The endogenous explanatory variable in the regression is the comprehensiveness of a firm’s EMS (the number of EMPs adopted by a firm). In one model we also use an interaction of count of EMPs with lagged TOTAL EMISSIONS/SALES as an explanatory variable to see if the impact of EMSs on more polluting firms was different from that on less polluting firms. The instruments for these endogenous variables consist of all the regressors hypothesized to be determinants of comprehensiveness of the EMS. Next, we discuss the empirical methodology. 3. Empirical framework 3.1. Determinants of the comprehensiveness of the environmental management system We measure the impact of market and (anticipated) regulatory pressures, W i ; on the comprehensiveness of the EMS using standard Poisson and Negative Binomial models [6]. We complement this analysis with the use of semiparametric, quantile regression-based methods [21,22]. The Poisson analysis estimates the expected number of EMPs as a function of firm characteristics. The Negative Binomial models provide an independent estimate of the variance of EMPs. Neither of these two methods provides a direct estimate of the impact of firm characteristics on the distribution of EMPs. While these models do imply a distribution for EMPs, this distribution is derived directly from the estimates of the mean and variance of EMPs and does not contain any additional information. For example, under the Poisson model, if an element of 6 We did not include the current number of inspections because of endogeneity concerns as the number of inspections could be related to emissions intensity. We did not have a good instrument for the number of current inspections, and in any case, the variable did not have a significant effect on adoption or on emissions-intensity. ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 639 W i increases the expected number of EMPs, it will (proportionately) scale the entire distribution of EMPs. On the other hand, quantile regressions provide an estimate of the effect of the regressors on each of the quantiles of the distribution of EMPs. They can show, for example, if a variable leads to an increase in the average number of EMPs adopted by firms by shifting the entire distribution of EMPs upwards, without changing its shape (indicating that all firms are equally affected by that variable), or by ‘‘stretching’’ the distribution of EMPs upwards, leaving the EMPs of firms in the lower tail unchanged and increasing the number of EMPs for firms in the upper tail (consistent with the hypothesis that low adopters either have little benefits from adoption or have high costs from adopting) or by ‘‘compressing’’ the distribution of EMPs upwards (consistent with the hypothesis that an increase in an explanatory variable wi provides greater returns for adoption to low adopters). In particular, we directly estimate the tth quantile of Ei ; Qt ðEi Þ; assuming that the quantiles are a linear function of the vector of observed characteristics, W i ; using the quantile regressions: Qt ðEi Þ ¼ gt W i : ð1Þ By estimating quantile regressions for a continuum of t we obtain estimates of the conditional distribution of Ei as a function of the characteristics, W i : Denote the predicted, conditional on W i ; value of Ei at the tth quantile by Q̂t ðEi jW i Þ: We calculate Q̂t ðEi jW i Þ for this fine grid of t; then plot the distribution of Ei in the form of a histogram. We use the quantile regressions results to plot the counterfactual distribution of EMPs if firms were to be endowed with different values of a regressor (holding the values of the other regressors constant at some particular level). This allows us to determine how changes in the regressors affect the entire distribution of Ei : 3.2. The analysis of the environmental performance of firms We estimate the impact of EMS adoption and other factors on aggregate releases per unit sales using IV methods. Further, to examine if EMS adoption has a differential impact on different types of pollutants or methods of disposal, we disaggregate total toxic releases into those emitted on-site, those transferred off-site, and HAP and estimate a system of three equations using Generalized Method of Moments (GMM). These equations are: yim ¼ X im b2 þ am Ei þ eim ; i ¼ 1; y; I; m ¼ 1ðon-siteÞ; 2ðoff-siteÞ; 3ðHAPÞ: ð2Þ The covariance between the errors across pairs of equations, eim and ein equals smn where m; n ¼ 1; y; 3 which is assumed to be homoskedastic and i.i.d. when m ¼ n and is non-zero when man; implying that the errors across equations are correlated. The main purpose of the disaggregated analysis is to investigate whether increasing the comprehensiveness of EMS has a differential impact on each type of emissions. Given that the scale of each type of emissions differs (HAP are a subset of on-site air releases, and off-site releases are of lesser magnitude than on-site releases), testing for equality of the response to improvements in EMS is facilitated by normalizing the emissions to output ratio of a particular type by the average emissions to output ratio of that type. Note that this normalization does not affect the level of significance of the regressors, but only rescales them so that they are comparable across equations. To maintain consistency and facilitate the interpretation of results, we perform a ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 640 similar normalization for the aggregate emissions to output ratio in the single-equation regression and also for aggregate emissions in the count model regressions. We recognize that a subset of the explanatory variables in our equations is endogenous. This includes the comprehensiveness of the EMS, Ei ; that the firms have adopted and any of its interactions with exogenous regressors. To deal with this endogeneity problem, we use a set of instruments, i.e., a set of variables that is correlated with the comprehensiveness of the EMS and uncorrelated with the disturbance terms. Let the combined vector of the exogenous explanatory variables and the instruments be zi which, by definition, satisfies the orthogonality conditions E½zi eim ¼ 0 ) E½zi ðyim bm Xi Þ ¼ 0; ð3Þ where yim denotes the dependent variable in equation m: The sample analog of the above orthogonality conditions is given by T 1X zi ðyim bm Xi Þ ¼ 0: T i¼1 ð4Þ The left-hand side of the system of equations is the vector of sample moments. The parameter vectors bm are estimated by choosing the values b# m that minimize a weighted sum of the squared sample moments. We use the inverse covariance matrix of the disturbance term as the weights in the minimization problem, which results in the three-stage least-squares (3SLS) estimates for the system of equations in (2) (see [12]). Unlike the ‘‘traditional’’ 3SLS estimation procedure, endogenous variables do not appear as dependent variables in any of the equations we estimate. However, the estimation procedure is identical to 3SLS in terms of the mechanics. For the single equation model in which the dependent variable is the ratio of total emissions to output, this procedure collapses to standard IV (or 2SLS) estimation. Our choice of the instrument vector, z; is based on the analysis of the determinants of the comprehensiveness of an EMS. In particular, all elements of W i are used as instruments for the system of Eq. (2). 4. Data This study relies on firm-level data on EMPs for S&P 500 firms included in the Corporate Environmental Profile Directories compiled from firm surveys by the Investor Research Responsibility Center for 1994–1995. The survey inquires about the adoption decision of firms for 13 EMPs described in Table 1. Additionally, we use primary data on environmental performance for 1994–1995 obtained from the TRI database, which contains facility-level information on chemical-specific toxic emissions. The TRI, which was first released in 1989, is mandated by the Emergency Planning and Community-Right-to-Know Act of 1986 and requires production facilities to report annual quantities of on-site toxic emissions to various media and the quantities of off-site transfers. These data are aggregated across chemicals and facilities of each parent company to obtain total on-site toxic releases and offsite transfers at the parent company level. We also obtain data at the parent company level on the volume of the 189 pollutants identified as HAP by the Clean Air Act of 1990. ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 641 Table 1 Description and adoption of environmental management practices Variable Mean values Description of the variable (1=yes; 0=no) Staff Directors Policy 0.49 0.47 0.93 Corp. stds. TQEM 0.40 0.71 Payments 0.62 Audits 0.92 Suppliers Partners Clients Report 0.53 0.41 0.11 0.39 Reserves 0.48 Insurance 0.44 Firm has an environmental staff of more than 50 Firm has more than 3 environmental directors Firm has a formal written policy and codes of conduct on environmental issues Firm applies uniform standards to environmental practices worldwide Firm applies principles of total quality management to environmental problems Firm provides incentive compensation to employees whose efforts lead to achievement of specific environmental goals Firm conducts audits to assess compliance with environmental regulations Firm evaluates its environmental risks when selecting its suppliers Firm evaluates its environmental risks when selecting its partners Firm evaluates its environmental risks when selecting its clients Firm regularly releases reports about its environmental performance and activities Firm sets aside funds to cover the costs of penalties for environmental violation or remediation activities Firm purchases insurance to meet unexpected environmental liabilities Information on regulatory inspections made on firms to check compliance with various environmental statutes is obtained from EPA’s publicly available Integrated Data for Enforcement Analysis. Data on the number of Superfund sites for which firms are held potentially liable are obtained from EPA’s Site Enforcement Tracking System [27]. Facilities (subsidiaries and divisions) within each parent company are identified by using Ward’s Business Directory of US Private and Public Companies [32]. Financial variables, such as net sales, R&D expenditures, and net and gross assets, are obtained from the Standard & Poor (S&P) 500 and Super Compustat databases which provide information on all publicly traded firms that file 10-K forms with the Securities and Exchange Commission. In the adoption decision equation, all time dependent explanatory variables are measured with a 5-year lag (i.e., for the years 1989 and 1990) since the adoption of some practices may have occurred prior to 1994 or 1995 and since the adoption decision is likely to depend on past levels of firm attributes. For the environmental performance regressions, pollution intensity (the dependent variable) is measured in 1994 and 1995. The time-dependent explanatory variables are measured contemporaneously. From the original 500 firms included in the 1994 and 1995 survey of S&P 500 firms we included only those firms that responded to the surveys, for which financial performance data were available for the years 1989, 1990, 1994 and 1995, and that emitted non-zero toxic emissions for at least one of the these 4 years. Tables 2 and 3 show the descriptions of the variables used in the study and their mean values. A pooled sample for the 2-year data were created for a total of 313 observations: 149 firms for 1994 ARTICLE IN PRESS 642 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 Table 2 Description and descriptive statistics of the dependent variables Dependent variables Description EMPt Number of environmental management practices adopted Total toxic emissions–sales ratio (pounds per dollar) On-site discharges of toxic emissions (pounds per dollar) Off-site transfers of toxic emissions for energy recovery, recycling, disposal (pounds per dollar) HAP–sales ratio (pounds per dollar) TOTAL RELEASESt/ SALESt ONSITEt/SALESt OFFSITEt/SALESt HAPt/SALESt Mean Std. dev. 6.92 3.22 1316.82 4343.89 659.18 2407.09 657.64 2378.53 256.19 543.26 and 164 firms for 1995 with 146 firms with observations that were common across both years.7 Of these 146 firms, 60 firms increased the number of EMPs they adopted while 12 firms decreased them. The average number of practices adopted for the sample increased from 6.6 to 7.2. The change in the number of EMPs between the 2 years in our sample is much smaller than the crosssectional variance in the number of EMPs. Therefore, it is the cross-sectional variation that provides most of the identifying power. Note that the distribution of lagged toxic releases per unit sales ranged from zero to 37,569 pounds per dollar of sales with 75% of the observations having a ratio less than the mean of 1661 pounds per dollar; the standard deviation of the distribution is 3928. This indicates a highly positively skewed distribution. The distribution of current toxic releases per unit sales is similarly positively skewed. As we discuss below, this has implications for the interpretation of the results and for our choice of specifications. 5. Results 5.1. Determinants of the comprehensiveness of environmental management 5.1.1. Results of Poisson models We estimate five different specifications of the Poisson model to examine the determinants of the comprehensiveness of the EMS adopted by the firms in our sample.8 Models 1P, 2P and 3P are estimated by pooling the data for 1994 and 1995. Models 1R and 3R have the same specifications as 1P and 3P, respectively, but are estimated using a random effects specification that recognizes the panel nature of our data (Table 4). The w2 test for firm random effects in Models 1R and 3R fails to reject the presence of persistence in the comprehensiveness of EMS at the firm level. 7 In models that use the variable, OTHER-EMPs, the sample consists of 242 observations. This is because firms in 3digit SIC codes which consist of only one firm had to be eliminated. 8 The likelihood ratio test for over-dispersion fails to reject the Poisson relative to the Negative Binomial models at the 1% level. The results of the two models are almost identical. ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 643 Table 3 Description and descriptive statistics of the independent variables Explanatory variables/instruments Description Mean Std. dev. TOTAL RELEASEt 5 Total toxic emissions (on-site emissions+off-site transfers) (’000 pounds) 11,200 31,900 TOTAL RELEASES/ SALESt 5 Total toxic emissions–sales ratio (pounds per dollar) 1660.84 ONSITEt 5 On-site discharges of toxic emissions (’000 pounds) 9678.41 OFFSITEt 5 Off-site transfers of toxic emissions for energy recovery, recycling, disposal (’000 pounds) 1518.18 3533.78 HAPt 5 Hazardous air pollutants (HAP) subject to NESHAP regulations in year 2000 (’000 pounds) 3352.12 7293.80 OTHER-EMPs Average number of environmental management practices adopted by all other firms in the sample within the same 3-digit SIC code 6.91 2.32 SUPERFUND SITESt Accumulated number of Superfund sites for which a firm is identified and potentially held responsible 22.79 30.08 13.85 17.87 33.97 52.82 SUPERFUND SITESt 5 3928.06 29,400 INSPECTIONSt 5 Number of regulatory compliance inspections received from the EPA FINAL GOOD Dummy (=1 if firm sells final goods; =0 otherwise) 0.62 0.49 SALES/ASSETt Sales–total assets ratio 1.08 0.46 1.13 0.49 SALES/ASSETt 5 NON USFACILITIES Number of facilities overseas 29.85 43.92 US-FACILITIES Number of facilities in the US 28.53 30.41 R&D/SALESt R&D expenditures–sales ratio 0.03 0.04 0.03 0.04 0.74 0.11 0.77 0.10 R&D/SALESt 5 AGE OF ASSETSt Gross assets/total assets AGE OF ASSETSt 5 Subscript t refers to 1994 and 1995 and t 5 refers to 1989 and 1990. ARTICLE IN PRESS 644 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 Table 4 Determinants of the comprehensiveness of environmental management: Poisson regression models Variables INTERCEPT INSPECTIONSt 5 SUPERFUND SITESt 5 FINAL GOOD TOTAL RELEASESt 5 (sqrt)a Model 1P Model 2P 2.11 (0.201) 0.0003 (0.0006) 0.003 (0.002) 0.264 (0.049) 0.089 (0.038) 1.56 (0.261) 0.0008 (0.0007) 0.005 (0.002) 0.270 (0.058) 0.158 (0.052) 0.0004 (0.0008) 0.0009 (0.0006) 0.399 (0.233) 1.38 (0.672) 0.218 (0.054) 0.000006 (0.001) 0.0006 (0.0006) 0.017 (0.273) 0.897 (0.768) 0.131 (0.075) 0.02 (0.01) FINALGOOD TOTAL RELEASESt 5 US-FACILITIES NON US-FACILITIES AGE OF ASSETSt 5 R&D/SALESt 5 SALES/ASSETSt 5 OTHER-EMPst Ln Alpha Alpha N Log L w2 fp-valuegb w2 fp-valuegc Pseudo-R2 Model 3P 2.00 (0.208) 0.00005 (0.0006) 0.003 (0.002) 0.373 (0.070) 0.219 (0.069) 0.166 (0.074) 0.0004 (0.0008) 0.0009 (0.0006) 0.385 (0.233) 1.80 (0.700) 0.212 (0.054) Model 1R 2.15 (0.305) 0.00007 (0.0009) 0.003 (0.002) 0.272 (0.071) 0.082 (0.061) 0.0004 (0.001) 0.001 (0.0009) 0.444 (0.355) 1.30 (1.02) 0.231 (0.077) Model 3R 2.03 (0.310) 0.0002 (0.0009) 0.004 (0.002) 0.398 (0.100) 0.227 (0.100) 0.200 (0.110) 0.0005 (0.001) 0.001 (0.0009) 0.446 (0.353) 1.77 (1.04) 0.227 (0.077) 2.33 2.36 (0.234) (0.236) 0.097 0.095 (0.023) (0.022) 313 242 313 313 313 776.59 612.33 774.16 752.36 750.71 139.15{0} 95.41{0} 144.02{0} 61.84{0} 65.89{0} 0.77{0.19} 1.71{0.095} 0.45{0.25} 48.47{0}d 46.89{0}d 0.079 0.072 0.084 Standard errors are in parentheses. Statistically significant at the 10% level; statistically significant at the 5% level; statistically significant at the 1% level; statistically significant at the 20% level. a Total releases for each firm are normalized so that the average of total releases is one. b 2 w {p-value} is a test for all slope coefficients jointly equal to zero. c 2 w {p-value} is a test for the null hypothesis that the Poisson model is appropriate. d This is the likelihood ratio test statistic of alpha=0. Random effects estimation does not affect the consistency of parameter estimates but it does provide correct standard errors under the null of gamma distributed random effects. All regression models are consistent in showing that firms that were listed as PRPs for a larger number of Superfund Sites and thus faced a stronger threat of future liabilities are more likely to ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 645 adopt a more comprehensive EMS, though its significance is lower in the random effects specifications. This is consistent with the hypothesis that environmental regulations do push firms towards being more proactive in managing their environmental performance. In contrast, the impact of the number of EPA inspections on EMS adoption is statistically insignificant. The lack of a positive impact of inspections indicates that EMSs are not being adopted to obtain a lenient treatment with regard to compliance with existing regulations. The pooled and the random effects models are also consistent in showing that larger polluters, measured by the squared root of total (normalized) toxic releases, are significantly more likely to adopt a more comprehensive EMS even though toxic releases are currently not directly penalized by mandatory regulations. This could be either to exploit the potential for cost-savings by reducing waste through proactive environmental management or in response to the performance of peer firms and the desire to avoid potentially adverse stakeholder reactions. Our hypothesis that the effect of emissions on the comprehensiveness of the EMS is likely to be characterized by a threshold and diminishing returns turns out to be correct: the log-likelihood of the specification in which the square root of emissions is used as a regressor is substantially higher than that of the specification using the linear measure of the variable.9 In order to confirm that the volume of toxic releases was not simply an indicator of firm size, we also estimated the models in Table 4 with lagged sales as an explanatory variable (results are not reported here for brevity). We found that the effect of the volume of total releases continued to be significant and positive even after we include sales as a variable while sales itself had an insignificant impact on the adoption decision. The significance of the remaining variables remains unchanged. The impact of peer pressure on adoption is also confirmed by Model 2P which shows that adoption of a large average number of EMPs by other firms in the same 3-digit SIC code has a statistically significant positive impact on the number of practices adopted by a firm. Our results also support the hypothesis that consumer pressure has a direct impact on a firm’s management strategies. Firms in closer contact with consumers are likely to be more environmentally proactive. This result corroborates findings in other studies [4,13,15,17]. Furthermore, both the pooled data Model 3P and the random effects Model 3R show that the interaction term between the variable final good and total releases emitted by a firm has a statistically significant negative effect on adoption. This indicates that, among smaller polluters, final good producing firms are more likely to adopt a more comprehensive EMS. This suggests that while larger polluters are motivated to adopt a more comprehensive EMS for a variety of other reasons, consumer pressure is important in inducing firms that would otherwise adopt a limited EMS.10 Furthermore, all the specifications in Table 4 show that firms with a high capital– output ratio (or a low sales–asset ratio), and thus more vulnerable to investor sentiment, are more likely to adopt a more comprehensive EMS. Parameter estimates of explanatory variables, age, non-US facilities and R&D/sales, have the expected sign but their significance is not robust across specifications. 9 The difference in the log-likelihood between the two models, which is a lower bound of the difference in the loglikelihood of a model is which the degree of concavity is estimated, is significant on the a basis of a likelihood ratio test with one degree of freedom. 10 Other measures of competitive pressure, such as the concentration of the industry as measured by the Herfindahl– Hirschman index, were not found to have a significant impact on the adoption decision. ARTICLE IN PRESS 646 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 Table 5 Determinants of comprehensiveness of environmental management: quantile regressions Variables Q10 Q30 Q50 Q70 Q90 INTERCEPT 1.89 (3.60) 1.57E 03 (0.01) 0.03 (0.03) 2.57 (0.59) 0.82 (0.56) 0.01 (9.27E 03) 8.32E 03 (7.09E 03) 1.66 (4.05) 11.56 (10.13) 0.75 (0.56) 0.1887 6.48 (2.46) 1.62E 03 (6.84E 03) 0.03 (0.01) 2.38 (0.46) 0.21 (0.59) 9.06E 05 (0.01) 8.62E 03 (6.00E 03) 3.01 (2.56) 10.97 (9.90) 1.19 (0.53) 0.1885 6.85 (1.67) 3.76E 03 (5.95E 03) 0.02 (0.01) 1.82 (0.36) 1.16 (0.55) 3.98E 03 (8.88E 03) 4.35E 03 (4.67E 03) 0.63 (2.03) 6.92 (7.10) 1.56 (0.46) 0.1919 10.63 (2.02) 5.37E 03 (7.67E 03) 0.02 (0.02) 1.21 (0.44) 0.76 (0.51) 5.06E 03 (5.68E 03) 8.35E 04 (5.47E 03) 3.43 (2.23) 17.37 (5.42) 1.57 (0.32) 0.1600 10.52 (1.34) 0.02 (6.13E–03) 8.44E 03 (0.01) 1.08 (0.42) 0.48 (0.39) 0.02 (7.85E 03) 9.31E 03 (4.66E 03) 1.43 (1.90) 1.05 (5.18) 0.42 (0.53) 0.1932 INSPECTIONSt 5 SUPERFUND SITESt 5 FINAL GOOD TOTAL RELEASESt 5 (sqrt)a US-FACILITIES NONUS-FACILITIES AGE OF ASSETSt 5 R&D/SALESt 5 SALES/ASSETSt 5 Pseudo-R2 Standard errors are in parentheses. Statistically significant at the 10% level; statistically significant at the 5% level; statistically significant at the 1% level; statistically significant at the 20% level. a Total releases for each firm are normalized so that the average of total releases is one. 5.1.2. Results of quantile regression analysis We use quantile regression methods to examine how the explanatory variables considered affect the distribution of EMPs. This distribution is not degenerate even after conditioning on all observed characteristics because firms differ in unobserved ways that are relevant to the comprehensiveness of their EMS. We refer to these ‘‘residual’’ unobserved differences as the propensity to adopt a more comprehensive EMS. Thus, the quantile regression results can be interpreted as investigating how the effect of the explanatory variables differs with respect to this unobserved propensity to adopt. The most important finding of this analysis, using the same specification as Model 1P of Table 4 (reported in Table 5), is that closeness to consumers not only has a statistically significant effect, but also one that is stronger for lower quantiles. In other words, the effect of being a final goods producer is stronger for firms with a relatively lower propensity to adopt a more comprehensive EMS (conditional on their other characteristics). The effect of the number of Superfund sites is broadly constant across quantiles, though it somewhat falls with the quantile level. There is no apparent relationship between the magnitude of the other coefficients and the quantile level.11 The 11 The results of quantile regressions using the same variables as Models 2 and 3 of Table 4 show effects that are qualitatively similar to those of the corresponding Poisson regressions and are omitted for brevity. ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 647 Fig. 1. Conditional distribution of EMPs. effect of being a final goods firm on the distribution of the count of adopted practices is examined graphically in Fig. 1 for two types of firms: a low toxic release emitter and a high toxic release emitter. In order to separately identify the effect of final good for the two types of firms we construct the figure using the results of quantile regressions specified as in Model 3P of Table 4 (that is including the interaction between final good and the square root of total emissions). The top left panel of Fig. 1 shows the distribution of EMPs for a firm with characteristics equal to that of the average firm in the sample, except that (i) its emissions are equal to the 10th percentile of the unconditional distribution of emissions and (ii) it is not a final goods producer. The top right panel of Fig. 1 shows the distribution of EMPs for the same set of firms had all of these firms been final goods producers. The upward shift in the support of the distribution is minimal. However, the shape of the distribution has changed radically: the bottom tail has thinned substantially, and the distribution exhibits a clear mode and a fatter upper tail. Clearly, among low emitters, the impact of being of a final goods producer is positive because final goods producers are very unlikely to be at the extreme low end of the distribution. This suggests that the effects of consumer-induced discipline are concentrated on firms that ‘‘fail to make the grade’’, i.e., if a firm is a laggard, it is likely to attract unwanted attention, but beyond a certain point it no longer obtains additional benefits from further adoption of EMPs. The bottom panels of Fig. 1 repeat this exercise, but condition on the emission level being equal to the 90th percentile of the ARTICLE IN PRESS 648 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 distribution of emissions. A few observations are in order. First, high emitters adopt a higher number of EMPs even conditional on not being final goods producers. Second, the effect of being a final goods producer is qualitatively similar for this group of firms as it is for the low emitters, but quantitatively less pronounced. Not only is the increase in the average number of EMPs smaller, but the thinning of the lower tail is less pronounced. This may be because high emitters probably have sufficiently strong incentives to adopt at least some EMPs. 5.2. The impact of the comprehensiveness of EMS on environmental performance We now examine the impact of the comprehensiveness of environmental management on the environmental performance of firms emitting toxic pollution. In order to test the robustness of the results, a number of specifications are estimated with different sets of explanatory variables and instruments. In Table 6, we present the results of the regression models with environmental performance measured by the ratio of aggregate toxic releases per unit sales (normalized so that the average value of that ratio equals 1). Model 1 uses OLS and ignores the endogeneity of the EMS adoption decision. This model shows that count of EMPs adopted had an insignificant impact on environmental performance possibly because firms with a high propensity to pollute are also more likely to adopt a more comprehensive EMS (thus biasing the coefficient of EMS upwards). We test the null hypothesis that the number of EMPs is exogenous using the Hausman Test [12]. We find that when we use only the regressors that are significant, we reject the null hypothesis of non-endogeneity; however, if we use all the regressors, we fail to reject the null hypothesis. This could be due to the fact that regressors which have no impact on the dependent variable are likely to have no significant effect on both the efficient and inefficient models and thus do not affect the vector of differences in the coefficients of the two models. They do, however, affect the degrees of freedom of the w2 test and therefore make it harder to reject the null hypothesis. Therefore, we use IV for the remaining models as discussed in Section 3.12 Model 2 shows that the comprehensiveness of the EMS has a statistically significant negative impact on total releases per unit sales. It also shows that the lagged level of total releases per unit sales has a very strong positive influence. We also find that the time trend variable has a significant positive effect, though the effect is not robust across specifications. Firms with a lower sales–asset ratio have a higher ratio of toxic releases per unit sales. Neither the other market pressure variable (FINAL GOOD), nor the threat of liabilities is statistically significant. While innovativeness of the firm and newer assets have a negative effect on releases per unit sales, the effect is not statistically significant. The coefficient of the EMS variable in Model 2 shows that an incremental change in the number of practices adopted lowers the pollution intensity by an amount that is equal to 79% of the average firm’s current emissions intensity (since current pollution intensity has been normalized to be one for an average firm). Observe that this effect appears large partly because it is the effect on the ‘‘treated’’ firms (i.e., the adopters) as a percentage of the emissions intensity of the average firm (including the adopters) rather than as a percentage of the intensity of 12 The standard errors reported in Tables 6 and 7 are asymptotic standard errors. We also computed boot-strapped standard errors by resampling entire histories of firms so as to account for the possibility of persistence in the residual. This approach is conservative in that it assumes perfect persistence. The boot-strapped standard errors are somewhat higher but overall significance of the results is not affected. Table 6 Determinants of aggregate toxic releases per unit sales Model 1 Model 2 Model 3 Model 4 OLS IV exclude OTHER-EMPs as instruments Model 5 IV include OTHER-EMPs Total releases/salest 5a p0.245b INTERCEPT EMPst 465.15 (524.53) 0.021 (0.048) EMPs TOTAL-RELEASE=SALESt 5 SUPERFUNDSITESt FINAL GOOD AGE OF ASSETSt YEAR US-FACILITIES NON US-FACILITIES R&D/SALESt SALES/ASSETSt N F-test [p-value] 0.988 (0.056) 0.002 (0.005) 0.684 (0.290) 0.959 (1.27) 0.233 (0.263) 0.003 (0.005) 0.001 (0.004) 7.56 (3.99) 0.210 (0.302) 313 0 1616.20 1664.93 96.213 1908.82 (797.61) (809.121) (114.89) (1322.29) 0.785 0.686 0.028 0.760 (0.246) (0.295) (0.028) (0.340) 0.071 (0.003) 1.02 1.69 1.44 0.991 (0.077) (0.935) (0.366) (0.103) 00.013 0.013 0.002 0.011 (0.008) (0.008) (0.001) (0.012) 0.674 0.682 0.012 0.007 (0.578) (0.584) (0.077) (0.858) 1.278 1.350 0.239 0.734 (1.86) (1.88) (0.275) (3.33) 0.814 0.838 0.048 0.961 (0.400) (0.406) (0.058) (0.664) 0.004 0.004 0.001 0.010 (0.007) (0.007) (0.001) (0.011) 0.007 0.006 0.0003 0.010 (0.006) (0.006) (0.001) (0.013) 1.54 1.08 0.712 0.806 (5.74) (5.84) (0.727) (13.90) 1.38 1.22 0.085 2.45 (0.549) (0.613) (0.057) (1.31) 313 313 157 156 0 0 0.019 0 953.94 (661.79) 0.389 (0.178) 1.29 (0.069) 0.012 (0.006) 0.243 (0.480) 0.610 (1.56) 0.479 (0.332) 0.002 (0.006) 0.002 (0.004) 5.22 (4.71) 0.542 (0.540) 242 0 Standard errors are in parentheses. The F-test is the test of significance of the regression. Statistically significant at the 10% level; statistically significant at the 5% level; statistically significant at the 1% level. a Total releases/sales for each firm is normalized so that the average is one. b This is the median level of (normalized) 5 year lagged total releases per unit sales. ARTICLE IN PRESS TOTAL RELEASES/SALESt 5a 40.245b W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 Variables 649 ARTICLE IN PRESS 650 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 the non-adopters.13 Further, it is possible that the effect of increasing the comprehensiveness of the EMS is higher for firms with higher pre-adoption pollution intensity. Therefore, when the benefits are compared to the emissions intensity of the average firm, the extent of reduction appears to be high. In Model 3 we attempt to control for this latter effect by including the interaction between count of EMPs and lagged toxic releases per unit sales as an endogenous explanatory variable. The coefficient of this interaction variable has a negative sign (suggesting that adoption had a larger effect on more pollution intensive firms) but it is not statistically significant. One possibility for the lack of significance may be the skewness in the distribution of emissions intensity: if there are any mild departures from linearity in the response of current total releases/sales to the interaction between EMPs and past total releases/sales, then this would manifest itself in a poor fit and in high standard errors. To further investigate the differential effect of adoption on firms of different emission intensities, we split the sample in two equal groups and estimate Model 3 for each of the subsamples (Model 4). Sub-sample 1 includes firms with a total releases/sales ratio of less than or equal to the sample median while sub-sample 2 includes the rest of the sample. Our analysis reveals a striking difference between the magnitude and the significance of the coefficient of EMPs for the two sub-samples. The effect of EMPs on firms with low pollution intensity in the past is negative but small and insignificant while on firms with high pollution intensity is large and significantly negative. This suggests that EMPs were beneficial in increasing efficiency and reducing waste generation at source, particularly among the more pollution intensive firms. In Model 5 we include OTHER-EMPs as an instrument (and consequently lose a number of observations) and find that the results remain the same as that obtained by Model 2. The comprehensiveness of the EMS has a negative significant effect on toxic releases per unit sales. The magnitude of the effect predicted by this model is, however, smaller than that predicted by Model 2. With regards to the remaining variables, all of the IV specifications estimated here are consistent in showing that market and regulatory pressures do not directly influence environmental performance. Rather, they play an indirect role in improving environmental performance by inducing adoption of a more comprehensive EMS. Their entire effect is embodied in institutional change and there is no incremental effect on toxic releases once this institutional change is accounted for. Finally, we examine the effect of adoption of an EMS on the intensity of different types of toxic releases by disaggregating total releases into those emitted on-site, those transferred off-site, and HAP. The results in Table 7 show the effect of adoption on ratios of these three categories of pollutants per unit sales for firms with past pollution intensity lower than that of the median firm, and for firms with past pollution intensity higher than that for the median firm. To maintain the full sample, we exclude OTHER-EMPs as an instrument. For firms that were more pollution 13 For example, suppose that the EMS adoption is described by a binary variable and consider a pool of homogeneous firms, 90% are adopters and 10% are non-adopters. Further suppose that adopters have emission intensity of zero, while non-adopters have emission intensity of 10. In a cross-section data set, the average emission intensity equals one and the coefficient on adoption equals 10, which is much higher than the intensity of the average firm in the sample. Variables INTERCEPT EMPst TOTAL RELEASES/SALESt 5a FINAL AGE OF ASSETSt YEAR US-FACILITIES NONUS-FACILITIES R&D/SALESt SALES/ASSETSt N w2 {p-value} TOTAL RELEASES/SALESt 5 40.245b ONSITE/SALES OFFSITE/SALES HAP/SALES ONSITE/SALES OFFSITE/SALES HAP/SALES 1.24 (30.57) 0.011 (0.007) 0.725 (0.097) 0.0001 (0.0004) 0.022 (0.204) 0.025 (0.073) 0.001 (0.015) 0.0003 (0.0003) 0.0003 (0.0002) 0.323 (0.193) 0.009 (0.015) 157 101.05 {0} 193.90 (217.09) 0.064 (0.052) 2.158 (0.691) 0.003 (0.003) 0.002 (0.145) 0.504 (0.519) 0.097 (0.108) 0.003 (0.002) 0.001 (0.002) 1.10 (1.373) 0.161 (0.108) 157 16.00 {0.100} 4.12 (44.57) 0.0184 (0.011) 1.063 (0.142) 0.0005 (0.0006) 0.010 (0.030) 0.064 (0.106) 0.002 (0.022) 0.0005 (0.0005) 0.0004 (0.0003) 0.631 (0.282) 0.019 (0.022) 157 89.18 {0} 1607.23 (1303.40) 0.714 (0.335) 1.23 (0.102) 0.009 (0.012) 0.942 (0.846) 0.012 (3.286) 0.810 (0.654) 0.015 (0.011) 0.008 (0.0130) 6.60 (13.69) 3.44 (1.29) 156 178.40 {0} 2211.12 (1544.57) 0.806 (0.397) 0.753 (0.121) 0.013 (0.014) 0.959 (1.002) 1.481 (3.894) 1.113 (0.775) 0.005 (0.013) 0.004 (0.015) 8.23 (16.22) 1.47 (1.53) 156 59.73 {0} 535.07 (823.03) 0.161 (0.212) 0.143 (0.064) 0.010 (0.007) 1.771 (0.534) 0.974 (2.075) 0.270 (0.413) 0.011 (0.007) 0.001 (0.008) 26.24 (8.66) 1.80 (0.814) 156 47.53 {0} Standard errors are in parentheses. Statistically significant at the 10% level; statistically significant at the 5% level; statistically significant at the 1% level. a Total releases/sales are normalized for each firm so that the average is equal to one. b This is the median level of (normalized) 5 year lagged total releases per unit sales. ARTICLE IN PRESS SUPERFUND SITESt TOTAL RELEASES/SALESt 5a p0.245b W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 Table 7 Determinants of disaggregated toxic releases per unit sales: split sample results 651 ARTICLE IN PRESS 652 W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 intensive, we find that adoption of a more comprehensive EMS has a significant negative impact on their on-site releases per unit sales and on off-site transfers per unit sales but an insignificant (although negative) impact on their HAP per unit sales. This could imply that EMSs were targeted broadly towards improving environmental performance and not towards reducing specific types of pollutants. We fail to reject the null that the magnitude of the coefficients of the EMS variable in the on-site release intensity and off-site release intensity models are the same. This implies that EMSs had a similar effect on on-site release intensity and on off-site release intensity. We also find that adoption of a more comprehensive EMS has no effect on any of the different types of releases per unit sales for firms that were less pollution intensive. For all firms, however, higher past pollution intensity contributes to higher current pollution intensity for all emission categories. This effect is significantly larger on current on-site release intensity as compared to off-site release intensity and HAP per unit sales. Consumer pressure has a positive but insignificant impact on on-site release intensity and a negative but insignificant impact on off-site release intensity. Surprisingly it has a positive and significant effect on HAP/sales. This could indicate that firms were able to use their EMSs to partially neutralize the direct effect of consumer pressure on toxic releases, particularly for HAP. Finally, we find that innovative firms, irrespective of their pollution intensity in the past, were making statistically significant reductions in their HAP/SALES ratio. However, innovativeness did not have a significant impact on on-site release intensity, off-site release intensity or on total releases/sales (by recalling the results of Table 6). This suggests that innovative firms are driven to reduce the types of pollutants that are more likely to be regulated in the future. 6. Conclusions Firms are increasingly addressing environmental concerns in a more proactive manner through the adoption of EMSs that integrate environmental considerations in various facets of production. Regulators are seeking to encourage this trend towards self-regulation by providing technical and financial assistance and through regulatory incentives. EMSs can differ considerably among firms in the comprehensiveness of their coverage and the ambitiousness of their goals. Analysis of the count of environmental practices adopted by S&P 500 firms shows that the threat of liabilities and market-based pressures from consumers, investors and other firms are significant motivators for the adoption of a more comprehensive EMS. Further, consumer pressure has a stronger effect on firms that would have otherwise been adopters of a less comprehensive EMS given their (other) characteristics. We also find that the adoption of a more comprehensive EMS has a significant negative impact on the intensity of toxic releases and that this impact is greater on firms that have inferior past environmental records. In addition, we find a differential impact of these incentives on a firm’s choice of pollution control method. Results show that EMSs have a negative effect on the intensity of on-site releases and off-site transfers, though not on HAP per unit sales. These findings suggest that adoption of EMSs leads to source reduction of total waste generation or to pollution prevention and reduces end-of-pipe disposal. By and large, none of the market-based or regulatory pressures considered are found to have had a significant direct impact on the pollution intensity of firms. Rather, their effect is indirect and operates through inducing the adoption of a ARTICLE IN PRESS W.R.Q. Anton et al. / Journal of Environmental Economics and Management 48 (2004) 632–654 653 more comprehensive EMS. Our results, taken together, suggest that public policy can play a role in inducing the prevention of toxic pollution by creating regulatory and market-based pressures that induce adoption of EMSs. These pressures include a threat of stringent mandatory regulation and the provision of environmental information about firms to the public. These results also suggest that promoting the adoption of EMSs particularly by firms with large toxic release intensity can be considered as an effective policy tool. Acknowledgments Senior authorship was not assigned. We would like to acknowledge financial support by the University of Illinois Campus Research Board and by USEPA’s National Center for Environmental Research, Science to Achieve Results (STAR) Program, Grant R827919-01. 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